ML19240B715

OMB 3150-0166, Final Supporting Statement for NRC Forms 541 and 541A

ML19240B715
Person / Time
Issue date:	10/07/2019
From:	David Cullison NRC/OCIO
To:
R GLADNEY MSST
Shared Package
ML19240B713	List: ML19240B715
References
OMB 3150-0166
Download: ML19240B715 (4)

Text

FINAL OMB SUPPORTING STATEMENT FOR NRC FORMS 541 AND 541A UNIFORM LOW-LEVEL RADIOACTIVE WASTE MANIFEST CONTAINER AND WASTE DESCRIPTION AND CONTINUATION PAGE (3150-0166)

EXTENSION Description of the Information Collection U.S. Nuclear Regulatory Commission (NRC) Form 541 and continuation Form 541A were developed by NRC in collaboration with the Department of Transportation (DOT). The completed NRC Forms 541 and 541A contain container and waste descriptions. Appendix G of 10 CFR Part 20 allows licensees to use substitute forms that are equivalent to the original documentation in respect to content, clarity, size, and location of information. Upon agreement between the shipper and consignee, the forms may be completed, transmitted, and stored in electronic media. The electronic media must have the capability for producing legible, accurate, and complete records in the format of the uniform manifest. Licensees can use software packages from several commercial vendors or can generate their own software package, provided that the forms are equivalent to the original documentation in respect to content, clarity, size, and location of information and include the OMB clearance number, expiration date, and Paperwork Reduction Act statement.

NRC Forms 541 and 541A are completed by specified shippers of low-level radioactive waste intended for ultimate disposal at a licensed land disposal facility. The disposal facilities and associated agreement states, if applicable, use the information found on the forms to ensure safe burial of the waste for the protection of the public and environment. The NRC does not collect or retain data on the forms and the forms are not sent to or received by the NRC.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information To meet existing regulations, each shipment of Low Level Waste (LLW), either directly or indirectly, to a licensed disposal facility is currently accompanied by a manifest that describes the shipment contents as required in 10 CFR Part 20 and the DOT regulations in 49 CFR Part 172. Presently, there are four LLW disposal facilities in operation. NRC Forms 541 and 541A contain information needed by disposal site facilities to safely dispose of low-level waste and information to meet NRC and State requirements regulating these activities. Licensees must use specified NRC forms, including NRC Forms 541 and 541A, pursuant to Appendix G to 10 CFR Part 20.

2. Agency Use of Information The agency and States require the information on NRC Forms 541 and 541A to control and safely regulate disposal of LLW.

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3. Reduction of Burden through Information Technology Appendix G of 10 CFR Part 20 allows licensees to use substitute forms that are equivalent to the original documentation in respect to content, clarity, size, and location of information. Upon agreement between the shipper and consignee, the forms may be completed, transmitted, and stored in electronic media. The electronic media must have the capability for producing legible, accurate, and complete records in the format of the uniform manifest. Several software packages (e.g. RADMAN and LowTrack) are available that can generate NRC Forms 541 and 541A electronically.

The information is not transmitted to the NRC.

4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.

5. Effort to Reduce Small Business Burden The required information is necessary from all shippers of LLW pursuant to Appendix G to 10 CFR Part 20. To the extent that small entities may make fewer waste shipments than larger entities, fewer manifests would be required of small entities and their burden would be proportionately less.

6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently If the collection is not conducted at all or is conducted less frequently, NRC and State regulatory agencies will not be able to obtain information needed to control and safely regulate disposal of LLW.

7. Circumstances Which Justify Variation from OMB Guidelines There are no variations from OMB guidelines.

8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on July 3, 2019 (84 FR 31931). No comments were received in response to the FRN. As part of the public consultation process, the NRC emailed five potential respondents from the LLW distribution list to request feedback on the four questions for which comments were specifically requested. These individuals were: Mike Elsen (State of Washington),

Susan Jenkins (State of South Carolina), Rusty Lundberg (State of Utah), Jennifer Opila (Colorado Department of Public Health and Environment), and Lisa Edwards (EPRI). No comments were received in response to these consultations.

9. Payment or Gift to Respondents Not applicable.

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10. Confidentiality of the Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered confidential or proprietary is requested.

11. Justification for Sensitive Questions This information collection does not involve sensitive questions.

12. Estimated Burden and Burden Hour Cost It is estimated that 5,600 NRC Forms 541 and 541A will be processed annually by 220 NRC and Agreement States licensees. It is assumed all shippers prepare the manifests electronically; therefore, the average burden to gather the information and record it on the form is estimated at 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The total industry burden for completing the form is estimated at 18,480 hours0.00556 days <br />0.133 hours <br />7.936508e-4 weeks <br />1.8264e-4 months <br /> annually (5,600 forms x 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).

The total industry cost to complete the forms is $5,082,000 (5,600 forms x 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to gather information x $275/hour).

The $275 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Average cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2018 (83 FR 29622, June 25, 2018).

13. Estimate of Other Additional Costs There are no other additional costs.

14. Estimated Annualized Cost to the Federal Government There are no annual cost printing and distribution costs to the Federal Government as the manifest forms are available for electronic downloading. Additionally, the forms are not submitted directly to the NRC, so there are no costs associated with processing or reviewing the forms.

15. Reasons for Changes in Burden or Cost There is no change in burden, but the hourly cost for professional staff has increased from $268/hour to $275/hour. This estimate assumes professional staff hours for all labor resulting in an increase in total cost of $2,604,560.

16. Publication for Statistical Use None.

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17. Reason for Not Displaying the Expiration Date The expiration date will be displayed on the hardcopy form. Electronic versions of NRC Forms 541 and 541A, provided in software to allow licensees to prepare the forms electronically, will also display an expiration date.

18. Exceptions to the Certification Statement There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS The collection of information does not employ statistical methods.